Everything Solar Forum

I just wrote this article on the changing landscape regarding the "rules and regulations" that DER (Distributed Energy Resources) is beginning to encounter. The article is in part general, but specifically mentions the utility environment I am dealing with in central PA. Its 1500+ words long. I could cut and paste, but I think it is easier and more efficient to just provide the link. What I am looking for are people who are encountering similar rules and or restrictions regarding implementing a new DER (Grid tied PV or Grid tied wind, etc..), and their experiences, positive or negative, etc...

Here is the link:

Balancing the Load.

EDIT: I guess some people don't want to bother with an extra click, I mean it was the single click "buy Box" that literally made Amazon a success. SO, here is the cut and paste:



D.E.R. (Distributed Energy Resource like Solar PV, Wind). You might want to make sure you have your morning coffee before reading this. A Distributed Energy Resource is energy production attached to “The Grid” (Sounds like Tron) that is not created by and directly controlled by the utility in their designated customer area. As of January 1st, 2021, PPL’s DER pilot program began. In its filling with the PUC (Public Utility Commission), PPL lays out its foundation for this project. The law firm representing PPL in the settlement is Post & Schell from Harrisburg. The filing is labeled as:

“Re: Petition of PPL Electric Utilities Corporation for Approval of Tariff Modifications and Waivers of Regulations Necessary to Implement its Distributed Energy Resources Management Plan Docket No. P-2019-3010128”

Continuing in the intro., “…...By way of background, many utilities have experienced operations and planning challenges as DER penetration becomes increasingly significant. These challenges include, but are not limited to, voltage swings, masked or hidden load, limited hosting capacity, planning uncertainties, and protection/operational challenges with two-way power flow. As a response to these challenges, the Institute of Electrical and Electronics Engineers (“IEEE”) made revisions to Standard 1547 in 2018 (“IEEE 1547-2018”), which set forth requirements for smart inverters that can help support the distribution system. When these smart inverters are coupled with DER management devices, electric utilities can monitor and manage DERs interconnected with their distribution systems. On May 24, 2019, PPL Electric filed a Petition with the Commission for permission to require smart inverters that meet the new IEEE and Underwriters Laboratories (“UL”) standards, to install DER management devices on new DERs interconnected with its distribution system, and to monitor and manage those new DERs. Ultimately, the parties agreed to the Settlement, which, as approved by the Commission, permits the Company to conduct a Pilot to test and evaluate the costs and benefits of monitoring and managing DERs……”

To put it simply, if you want to produce power on our grid, we want to control and manage it. Really? Let’s step back a bit to a time when there was mostly only one kitchen in the house for food prep.. Any customer wanting service from their electric utility, requests a service connection (Residential, commercial, industrial), and via an appropriately sized transformer(s) for their expected load, connects to the transformer through a power meter (usage and peak demand in KWH’s) to the customer installed electrical infrastructure (Main breaker panel, sub-panels, associated wiring to outlets and lights, etc.). The utility in NO WAY has control of ANY of the loads behind the power meter (Customer side). Imagine the following fictious conversation:

The Benton Foundry wants to “come on line” with their new business. After all is setup and ready to go, the utility says, “We want to connect to your load panel behind the meter to better control and balance your loads. Your foundry has large inductive and resistive loads which can introduce noticeable frequency, voltage and current shifts that could adversely affect other customers in your local area. By attaching our L.M.D. (Load Management Device) we can better control the quality of the electric power on the primary side for all attached customers.” Possible response from Benton Foundry, “Excuse Me? We will be paying you for power 24/7 which we will use when and how much we need for our business needs. It is up to you to make that happen out on your end any way you see fit. Anything on “your side of the meter” is your problem, not ours. But we will use the power anyway, any time we want for our requirements which we pay you for.”

My simplified hypothetical conversation would be short and sweet (Well, maybe not sweet) most likely. I chose the Benton Foundry because I know people (Residential customers) that have had power stabilization issues (like the issues laid out in the DER request, voltage, frequency, etc..) over time in the Foundry’s area. These are real stubborn issues that the utility has to deal with from an engineering and bureaucratic perspective. But what does not happen, is the utility telling the customer (B.F.) that they get to actively manage when and how the customer uses the energy their providing, for the utilities quality management benefit.

There is no doubt that RE (Renewable Energy) is an increasing part of the grid mix, and that part is happening at an accelerating rate (Though not fast enough). The percentages of RE in the grid mix for most areas is still small, particularly solar and wind. There are however geographic areas where the amount of RE is becoming very noticeable. For a moment, lets visit the reason for the uptick in RE. CO2 is on track to wipe out our reality as we know it. It is being caused by Fossil Fuel burning. Period. I am not going to debate this, anymore then I would debate the color of the sky on a clear sunny day. Given the need and increase for DER (Distributed Energy Resources) as one of the components to achieve a 100% RE world, it is not un-reasonable that the utilities would want visibility and control of these DER’s for engineering reasons.

The core business problem from a Capitalistic perspective is that DER energy per KWH makes the utility no money. No profit. In short, it is a classic example of demand destruction. SO the more DER increases, the greater the threat to the utilities survival (Under the current business model). From the utilities perspective it is an emerging evil. The last time I checked, wiping out our climate and us, does not occupy a column on the General Ledger. But selling less and less KWH certainly does. Additionally to the demand destruction, there is a cost associated in morphing a centralized energy system into a distributed energy system. And that cost must be shared by not only the new RE producers, but by the holders of the distribution infrastructure as well (Utilities and Grid providers like PPL and PJM). Ironically the initial push for Grid tied PV (Photovoltaics) was supported by the electric utilities because it allowed them in the Summer, to hugely decrease the peak load KWH charges they (The utility) had to pay the grid providers. The cost curve was so steep that a small investment into a small allowed amount of DER, could save them a boat load of costs during Summer peaking (Air Conditioning time)! Imagine that. However with climate destruction, the small amount of hot sauce flavoring the meal, is turning into a mouth on fire. Once again, size matters.

As often occurs in a currency based world, the right direction to take is in direct conflict with making money. The profit temptations for a utility holding RE production down, from less DER energy allowed on the grid to delaying infrastructure changes for it, is not in totality, in their profit interests. The fox will not regulate itself in terms of how many hens it wants or will eat. Thus the PUC and the DER pilot settlement. The dangers going forward are somewhat self-evident. Cutting off inverter implementations for those inverters that are already in the channel, or legacy inverters that may be able to be put back in service for a new array, will be denied connectivity to the grid, whether or not the 3000 systems per year quantity has been met for the pilot. This is at least the overt way the restrictions are being worded on PPL’s site. The current list of allowed inverters leaves a huge number of inverters that normally could be used for a system out of the equation, that have not or will never be tested for system pilot usage. Having a $4000 or $5000 inverter sitting on the floor that is perfectly good, in favor of spending $4000 or $5000 more for an inverter that meets the pilot programs DER “need”, if true, is neither sustainable or desirable for the individual participant. This equates to increased cost for a technology that we desperately need implemented in huge numbers, yesterday. I personally am not aware if this particular scenario has been challenged to date. I hope if it is, or was, PPL will simply allow these legacy solutions to pass through the gate of system implementation. After all, it is just a pilot program.

As this process moves forward across the country, I am sure there will be many restrictions being put forth, honestly and dis-honestly towards the continued increase in RE and DER systems, from entities that have not changed or are unwilling to change their business model, to accommodate our badly needed new energy world.

------------------------------
william fitch
Owner
www.WeAreSolar.com
fcfcfc@ptd.net
------------------------------

William, I am not the sort of people you are looking for, but I would like to comment. Your article touched on, but I think did not emphasize, the core issue - Bureaucratic inflexibility and "the way we've always done it", perhaps coupled with a lack of imagination regarding their future role, on the part of "capitalist" electricity providers like PP&L. Assuring return on capital (ROI) has been the way government utility-regulating agencies have usually set rates. Is it any wonder that their regulated utilities see themselves as "capitalist" enterprises?
It is obvious that a human-compatible global environment can no longer endure CO2-producing traditional coal or gas-fired baseload and natural gas "peaking" electrical generation. Looking to the future, centralized power production will continue to utilize hydro and nuclear, and perhaps someday "clean" fusion. But until (if ever) controlled fusion becomes a reality, our future carbon-free electricity needs will likely be met primarily by distributed energy resources ("DER"), largely wind and pv.
This can go in one of two ways - 
(1). Our electrical utilities can be part of the solution by recasting themselves from their emphasis on being power generators (with distribution being necessary only in order to "deliver the goods") to being primarily in the electrical storage and distribution business - i.e., emphasizing moving distributed energy from when and where it is being produced to when and where it is needed; or
(2) Distributed energy producers (i.e., owners of wind or pv systems) can make their own "capital-intensive" investments in local storage, and drop off the grid altogether.
Only by shifting their focus from power generation to meeting their customers' energy needs via redistribution of "DER', can today's electrical utilities assure they will continue to have a key role to play in the future.
The "Achilles heel" of DER is storage, and it is expensive. The distributed energy resources (mainly pv and wind) are not always needed when they are available, and aren't available when and where they are needed. Balancing these mismatches may be the key role for electric utilities in future.
I am sympathetic to the traditional electrical utilities' need to figure out how they can balance DER production and use. I expect they realize they must somehow figure it out, or like buggy whip manufacturers they will fall by the wayside. PP&L may be a bit late coming to the party, but it seems they are (albeit slowly and with some difficulty) trying. 
I suspect the bigger hurdle might be getting the regulatory bureaucracy to figure out how their rate-setting practices will need to change in order to allow the regulated utilities to continue to make a fair profit while making major new investments in storage and distribution while phasing out their traditional CO2-emitting plants, all while adapting to DER and their customers' changing needs.

------------------------------
Hugh Willis
Old Engrs Never Really Retire
GREENSBORO, NC
------------------------------

Original Message:
Sent: Oct 20, 2021 07:14 AM
From: william fitch
Subject: Balancing the load.

I just wrote this article on the changing landscape regarding the "rules and regulations" that DER (Distributed Energy Resources) is beginning to encounter. The article is in part general, but specifically mentions the utility environment I am dealing with in central PA. Its 1500+ words long. I could cut and paste, but I think it is easier and more efficient to just provide the link. What I am looking for are people who are encountering similar rules and or restrictions regarding implementing a new DER (Grid tied PV or Grid tied wind, etc..), and their experiences, positive or negative, etc...

Here is the link:

Balancing the Load.

------------------------------
william fitch
Owner
www.WeAreSolar.com
fcfcfc@ptd.net
------------------------------

Hi Hugh: 

Thank you for the thoughtful reply. Despite my initial desired response categorization expectation, I really judge benefit by content.
To yours, I believe both 1 & 2 will be the outcomes, baring Mr. Sun on home planet Earth. Given this sites "intent" and unspoken most probable guidelines, I try and temper my comments in a more conservative, less inflammatory way. 
I totally agree that their survivable direction is to become "mini grid providers". PPL has already dropped allot of their raw production, apparently moving themselves in that direction. In addition to storage,  massive low temp DC lines connecting the West coast to the East coast, would allow a 6 hour "shortening" of the "No Sun Zone", each side benefiting 3 hours, morning then evening. This is the kind of "Roman Aqua System" venture that government is made for, coupling along with the private sector. Similar cases can be made for North South connections as well, to balance sunnier to not so sunny. Additionally as I was also warning, extreme care must be taken that the new product (RE) that is needed is not suppressed as a trade off to lower cost. Hen must not be on the menu.
To put it compactly, my article was also warning not to step on the little guy (Residential), while trying to sweep a tidal wave along, not that this ever happens (Oops..that popped out).  
Thanks again....
.....Bill

------------------------------
william fitch
Owner
www.WeAreSolar.com
fcfcfc@ptd.net
------------------------------

Original Message:
Sent: Oct 22, 2021 07:38 AM
From: Hugh Willis
Subject: Balancing the load.

William, I am not the sort of people you are looking for, but I would like to comment. Your article touched on, but I think did not emphasize, the core issue - Bureaucratic inflexibility and "the way we've always done it", perhaps coupled with a lack of imagination regarding their future role, on the part of "capitalist" electricity providers like PP&L. Assuring return on capital (ROI) has been the way government utility-regulating agencies have usually set rates. Is it any wonder that their regulated utilities see themselves as "capitalist" enterprises?
It is obvious that a human-compatible global environment can no longer endure CO2-producing traditional coal or gas-fired baseload and natural gas "peaking" electrical generation. Looking to the future, centralized power production will continue to utilize hydro and nuclear, and perhaps someday "clean" fusion. But until (if ever) controlled fusion becomes a reality, our future carbon-free electricity needs will likely be met primarily by distributed energy resources ("DER"), largely wind and pv.
This can go in one of two ways - 
(1). Our electrical utilities can be part of the solution by recasting themselves from their emphasis on being power generators (with distribution being necessary only in order to "deliver the goods") to being primarily in the electrical storage and distribution business - i.e., emphasizing moving distributed energy from when and where it is being produced to when and where it is needed; or
(2) Distributed energy producers (i.e., owners of wind or pv systems) can make their own "capital-intensive" investments in local storage, and drop off the grid altogether.
Only by shifting their focus from power generation to meeting their customers' energy needs via redistribution of "DER', can today's electrical utilities assure they will continue to have a key role to play in the future.
The "Achilles heel" of DER is storage, and it is expensive. The distributed energy resources (mainly pv and wind) are not always needed when they are available, and aren't available when and where they are needed. Balancing these mismatches may be the key role for electric utilities in future.
I am sympathetic to the traditional electrical utilities' need to figure out how they can balance DER production and use. I expect they realize they must somehow figure it out, or like buggy whip manufacturers they will fall by the wayside. PP&L may be a bit late coming to the party, but it seems they are (albeit slowly and with some difficulty) trying. 
I suspect the bigger hurdle might be getting the regulatory bureaucracy to figure out how their rate-setting practices will need to change in order to allow the regulated utilities to continue to make a fair profit while making major new investments in storage and distribution while phasing out their traditional CO2-emitting plants, all while adapting to DER and their customers' changing needs.

------------------------------
Hugh Willis
Old Engrs Never Really Retire
GREENSBORO, NC

Original Message:
Sent: Oct 20, 2021 07:14 AM
From: william fitch
Subject: Balancing the load.

I just wrote this article on the changing landscape regarding the "rules and regulations" that DER (Distributed Energy Resources) is beginning to encounter. The article is in part general, but specifically mentions the utility environment I am dealing with in central PA. Its 1500+ words long. I could cut and paste, but I think it is easier and more efficient to just provide the link. What I am looking for are people who are encountering similar rules and or restrictions regarding implementing a new DER (Grid tied PV or Grid tied wind, etc..), and their experiences, positive or negative, etc...

Here is the link:

Balancing the Load.

------------------------------
william fitch
Owner
www.WeAreSolar.com
fcfcfc@ptd.net
------------------------------